IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`IMMERVISION, INC.
`
`Plaintiff,
`
`v.
`
`LG ELECTRONICS U.S.A., INC. AND
`LG ELECTRONICS INC.
`
`Defendants.
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`CA No. 1:18-cv-01630-MN-CJB
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF’S INITIAL INFRINGEMENT CONTENTIONS
`
`Pursuant to the Scheduling Order (D.I. 23), plaintiff ImmerVision, Inc. (“ImmerVision”)
`
`hereby submits its Initial Infringement Contentions and claim charts.
`
`The patent in suit is U.S. Patent No. 6,844,990 (“the ‘990 Patent”). Claim 21 of the ‘990
`
`Patent is asserted in this litigation against the LG G7 series, V30 series, V35 series, G8 series,
`
`and V50 series smartphones and any other phones or devices having the same wide-angle lens
`
`array, as shown in the following attached exhibits:
`
`Exhibit A – ‘990 Patent v. LG G7 series smartphone;
`
`Exhibit B – ‘990 Patent v. LG V30 series smartphone;
`
`Exhibit C – ‘990 Patent v. LG V35 series smartphone;
`
`Exhibit D – ‘990 Patent v. LG G8 series smartphone; and
`
`Exhibit E – ‘990 Patent v. LG V50 series smartphone.
`
`ImmerVision submits that the pertinent field of art for claim 21 of the ‘990 Patent is
`
`optical lens design, and that one of ordinary skill in the art will have at least a master’s degree in
`
`optics or a related discipline and at least three years work experience in optical design.
`
`ImmerVision asserts that the described LG products infringe claim 21 of the ‘990 Patent,
`
`either literally or under the doctrine of equivalents, in accordance with the attached Exhibits.
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 1 of 23
`
`
`FOR THE DISTRICT OF DELAWARE
`
`IMMERVISION, INC.
`
`Plaintiff,
`
`v.
`
`LG ELECTRONICS U.S.A., INC. AND
`LG ELECTRONICS INC.
`
`Defendants.
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`CA No. 1:18-cv-01630-MN-CJB
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF’S INITIAL INFRINGEMENT CONTENTIONS
`
`Pursuant to the Scheduling Order (D.I. 23), plaintiff ImmerVision, Inc. (“ImmerVision”)
`
`hereby submits its Initial Infringement Contentions and claim charts.
`
`The patent in suit is U.S. Patent No. 6,844,990 (“the ‘990 Patent”). Claim 21 of the ‘990
`
`Patent is asserted in this litigation against the LG G7 series, V30 series, V35 series, G8 series,
`
`and V50 series smartphones and any other phones or devices having the same wide-angle lens
`
`array, as shown in the following attached exhibits:
`
`Exhibit A – ‘990 Patent v. LG G7 series smartphone;
`
`Exhibit B – ‘990 Patent v. LG V30 series smartphone;
`
`Exhibit C – ‘990 Patent v. LG V35 series smartphone;
`
`Exhibit D – ‘990 Patent v. LG G8 series smartphone; and
`
`Exhibit E – ‘990 Patent v. LG V50 series smartphone.
`
`ImmerVision submits that the pertinent field of art for claim 21 of the ‘990 Patent is
`
`optical lens design, and that one of ordinary skill in the art will have at least a master’s degree in
`
`optics or a related discipline and at least three years work experience in optical design.
`
`ImmerVision asserts that the described LG products infringe claim 21 of the ‘990 Patent,
`
`either literally or under the doctrine of equivalents, in accordance with the attached Exhibits.
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 1 of 23
`
`
`
`The analyses shown in the attached Exhibits were undertaken according to the following
`
`procedure.
`
`The wide-angle lens of each phone was analyzed by opening the phone, removing the
`
`lens from the wide-angle camera module, and measuring the distortion using an Optikos
`
`LensCheck VIS machine. The Optikos outputs an Excel file showing the distortion profile of the
`
`lens as shown in the position and resolution graphs in the attached claim charts. After analysis
`
`by the Optikos, the lens was cut by placing it on a glass slide, covering the lens using 2-ton
`
`epoxy manufactured by Devcon, and allowing the epoxy to dry for 24 hours. The lens is cut
`
`using a Disco DAD3350 dicing saw using a 90 mm diameter, 0.4 mm thick saw blade, in the
`
`multi-pass operating mode at 400µm ≤ Z-Cut ≤ 700µm.
`
` ImmerVision notes that discovery is ongoing and therefore reserves the right to amend,
`
`modify, or supplement, without prejudice, these Initial Infringement Contentions, including but
`
`not limited to the products being accused and the bases for infringement, as additional facts are
`
`ascertained through discovery and additional testing, analyses are made, Defendants’ positions
`
`shift, and through the litigation process in accordance with the rules of the Court.
`
`Dated: October 25, 2019
`
` Of Counsel:
`
`Keith A. Jones (pro hac vice)
`Panitch Schwarze Belisario & Nadel LLP
`Two Commerce Square
`2001 Market Street, Suite 2800
`Philadelphia, PA 19103
`Telephone: (215) 965-1330
`kjones@panitchlaw.com
`
`
`
`
`
`
`PANITCH SCHWARZE BELISARIO & NADEL, LLP
`
`By: /s/ Keith A. Jones
`John D. Simmons (Bar No. 5996)
`Dennis J. Butler (Bar No. 5981)
`Wells Fargo Tower
`2200 Concord Pike, Suite 201
`Wilmington, DE 19803
`Telephone: (302) 394-6030
`jsimmons@panitchlaw.com
`dbutler@panitchlaw.com
`
`Attorneys for Plaintiff ImmerVision, Inc.
`
`2
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 2 of 23
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on October 25, 2019, a true and correct copy of PLAINTIFF’S
`
`INITIAL INFRINGEMENT CONTENTIONS was served upon the following via electronic
`
`mail:
`
`John V. Gorman (#6599)
`Amy M. Dudash (#5741)
`MORGAN, LEWIS & BOCKIUS LLP
`The Nemours Building
`1007 N. Orange Street, Suite 501
`Wilmington, DE 19801
`john.gorman@morganlewis.com
`amy.dudash@morganlewis.com
`
`Collin W. Park (pro hac vice)
`Jeremy Peterson (pro hac vice)
`MORGAN, LEWIS & BOCKIUS LLP
`1111 Pennsylvania Avenue NW
`Washington, DC 20004
`collin.park@morganlewis.com
`jeremy.peterson@morganlewis.com
`
`Andrew V. Devkar (pro hac vice)
`MORGAN, LEWIS & BOCKIUS LLP
`2049 Century Park East, Suite 700
`Los Angeles, CA 90067
`andrew.devkar@morganlewis.com
`
`/s/ Keith A. Jones
`Keith A. Jones
`
`3
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 3 of 23
`
`
`
`Claim
`
`17. A panoramic objective lens
`comprising:
`optical means for projecting
`a panorama into an image
`plane of the objective lens,
`the optical means having an
`image point distribution
`function that is not linear
`relative to the field angle of
`object points of the panorama,
`the distribution function having
`a maximum divergence of at
`least ±10% compared to a
`linear distribution function,
`such that a panoramic image
`obtained by means of the
`objective lens comprises at
`least one substantially
`expanded zone and at least one
`substantially compressed zone.
`
`21. The panoramic objective
`lens according to claim 17,
`wherein the lens compresses
`the center of the image and the
`edges of the image, and
`expands an intermediate zone
`of the image located between
`the center and the edges of the
`image.
`
`US PATENT 6,844,990, CLAIM 21 v. LG G7 SERIES SMARTPHONE
`
`LG G7 Series Smartphone
`
`As shown in the cross-sectional cut above (produced at IV0004045), the objective lens array within the LG G7
`contains a series of six lenses which, when coupled together as in the LG G7, form an objective lens that projects
`a panoramic image as described in the ‘990 Patent.
`
`1
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 4 of 23
`
`
`
`Claim
`
`17. A panoramic objective lens
`comprising:
`optical means for projecting a
`panorama into an image plane
`of the objective lens, the
`optical means having an
`image point distribution
`function that is not linear
`relative to the field angle of
`object points of the
`panorama, the distribution
`function having a maximum
`divergence of at least ±10%
`compared to a linear
`distribution function, such that
`a panoramic image obtained by
`means of the objective lens
`comprises at least one
`substantially expanded zone
`and at least one substantially
`compressed zone.
`
`21. The panoramic objective
`lens according to claim 17,
`wherein the lens compresses
`the center of the image and the
`edges of the image, and
`expands an intermediate zone
`of the image located between
`the center and the edges of the
`image.
`
`LG G7 Series Smartphone
`
`The above plot shows a normalized, linear point distribution function of an objective lens as a red line, wherein
`the Y axis represents the position of a point in an image with respect to the image center, and the X axis
`represents the field angle in degrees of the corresponding object point.
`
`The above plot also shows, in blue dots, measured position and field angle data (acquired using an Optikos
`LensCheck VIS and produced as IV0004044) for the wide-angle objective lens found in the LG G7. The lens
`array is panoramic as the lens reaches over 55 degrees away from center, resulting in a total field of view over 110
`degrees. The deviation of the function for the LG G7 objective lens away from the red line and multiple
`inflection points indicates that the image point distribution function of the LG G7 objective lens is not linear.
`
`2
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 5 of 23
`
`
`
`Claim
`
`17. A panoramic objective lens
`comprising:
`optical means for projecting a
`panorama into an image plane
`of the objective lens, the
`optical means having an image
`point distribution function that
`is not linear relative to the field
`angle of object points of the
`panorama, the distribution
`function having a maximum
`divergence of at least ±10%
`compared to a linear
`distribution function, such
`that a panoramic image
`obtained by means of the
`objective lens comprises at
`least one substantially
`expanded zone and at least one
`substantially compressed zone.
`21. The panoramic objective
`lens according to claim 17,
`wherein the lens compresses
`the center of the image and the
`edges of the image, and
`expands an intermediate zone
`of the image located between
`the center and the edges of the
`image.
`
`
`
`
`
`LG G7 Series Smartphone
`
`
`As shown in row 236 of the raw data taken from the measured point data of the LG G7 objective lens (produced at
`IV0004044), the image point distribution of the LG G7 objective lens has a maximum divergence from the linear
`distribution function of over 17%, exceeding the 10% divergence required by claim 17 of the ‘990 Patent.
`
`3
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 6 of 23
`
`
`
`Claim
`
`17. A panoramic objective lens
`comprising:
`optical means for projecting a
`panorama into an image plane
`of the objective lens, the
`optical means having an image
`point distribution function that
`is not linear relative to the field
`angle of object points of the
`panorama, the distribution
`function having a maximum
`divergence of at least ±10%
`compared to a linear
`distribution function, such that
`a panoramic image obtained
`by means of the objective
`lens comprises at least one
`substantially expanded zone
`and at least one substantially
`compressed zone.
`
`21. The panoramic objective
`lens according to claim 17,
`wherein the lens compresses
`the center of the image and
`the edges of the image, and
`expands an intermediate
`zone of the image located
`between the center and the
`edges of the image.
`
`Compressed
`edges
`
`LG G7 Series Smartphone
`
`Compressed center zone
`
`Compressed
`edges
`
`Expanded
`intermediate zone
`
`Expanded
`intermediate zone
`
`As indicated by its title, the above plot (produced as IV0004044) represents the derivatives of the linear point
`distribution function and the point distribution function of the LG G7 objective lens shown above. The Y axis
`represents the image resolution (in microns per degree) and the X axis represents the corresponding field angle of
`the lens. The LG G7 objective lens produces images with two substantially compressed zones: at the center of the
`image and around the edges of the image, where the blue dots fall below the red reference line, representing
`smaller resolution in these areas than a lens having a linear point distribution function. The LG G7 objective lens
`also produced a substantially expanded zone in between, from approximately 30 degrees to approximately 55
`degrees, where the blue dots rise above the red reference line, representing a higher resolution in this area than a
`lens having a linear point distribution function.
`
`4
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 7 of 23
`
`
`
`Claim
`
`17. A panoramic objective lens
`comprising:
`
`optical means for projecting
`a panorama into an image
`plane of the objective lens,
`the optical means having an
`image point distribution
`function that is not linear
`relative to the field angle of
`object points of the panorama,
`the distribution function having
`a maximum divergence of at
`least ±10% compared to a
`linear distribution function,
`such that a panoramic image
`obtained by means of the
`objective lens comprises at
`least one substantially
`expanded zone and at least one
`substantially compressed zone.
`
`21. The panoramic objective
`lens according to claim 17,
`wherein the lens compresses
`the center of the image and the
`edges of the image, and
`expands an intermediate zone
`of the image located between
`the center and the edges of the
`image.
`
`US PATENT 6,844,990, CLAIM 21 v. LG V30 SERIES SMARTPHONE
`
`LG V30 Series Smartphone
`
`As shown in the cross-sectional cut above (produced at IV0004043), the objective lens array within the LG V30
`contains a series of six lenses which, when coupled together as in the LG V30, form an objective that projects a
`panoramic image as described in the ‘990 Patent.
`
`1
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 8 of 23
`
`
`
`Claim
`
`17. A panoramic objective lens
`comprising:
`
`optical means for projecting a
`panorama into an image plane
`of the objective lens, the
`optical means having an
`image point distribution
`function that is not linear
`relative to the field angle of
`object points of the
`panorama, the distribution
`function having a maximum
`divergence of at least ±10%
`compared to a linear
`distribution function, such that
`a panoramic image obtained by
`means of the objective lens
`comprises at least one
`substantially expanded zone
`and at least one substantially
`compressed zone.
`
`21. The panoramic objective
`lens according to claim 17,
`wherein the lens compresses
`the center of the image and the
`edges of the image, and
`expands an intermediate zone
`of the image located between
`the center and the edges of the
`image.
`
`LG V30 Series Smartphone
`
`The above plot shows a normalized, linear point distribution function of an objective lens as a red line, wherein
`the Y axis represents the position of a point in an image with respect to the image center, and the X axis
`represents the field angle in degrees of the corresponding object point.
`
`The above plot also shows, in blue dots, measured position and field angle data (acquired using an Optikos
`LensCheck VIS and produced as IV0004042) for the wide-angle objective lens found in the LG V30. Te lens
`array is panoramic as the lens reaches over 60 degrees away from center, resulting in a total field of view over 120
`degrees. The deviation of the function for the LG V30 objective lens away from the red line and multiple
`inflection points indicates that the image point distribution function of the LG V30 objective lens is not linear.
`
`2
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 9 of 23
`
`
`
`Claim
`
`17. A panoramic objective lens
`comprising:
`
`optical means for projecting a
`panorama into an image plane
`of the objective lens, the
`optical means having an image
`point distribution function that
`is not linear relative to the field
`angle of object points of the
`panorama, the distribution
`function having a maximum
`divergence of at least ±10%
`compared to a linear
`distribution function, such
`that a panoramic image
`obtained by means of the
`objective lens comprises at
`least one substantially
`expanded zone and at least one
`substantially compressed zone.
`
`21. The panoramic objective
`lens according to claim 17,
`wherein the lens compresses
`the center of the image and the
`edges of the image, and
`expands an intermediate zone
`of the image located between
`the center and the edges of the
`image.
`
`
`
`
`
`LG V30 Series Smartphone
`
`
`As shown in row 209 of the raw data taken from the measured point data of the LG V30 objective lens (produced
`at IV0004042), the image point distribution of the LG V30 objective lens has a maximum divergence from the
`linear distribution function of over 20%, exceeding the 10% divergence required by claim 17 of the ‘990 Patent.
`
`3
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 10 of 23
`
`
`
`Claim
`
`17. A panoramic objective lens
`comprising:
`
`optical means for projecting a
`panorama into an image plane
`of the objective lens, the
`optical means having an image
`point distribution function that
`is not linear relative to the field
`angle of object points of the
`panorama, the distribution
`function having a maximum
`divergence of at least ±10%
`compared to a linear
`distribution function, such that
`a panoramic image obtained
`by means of the objective
`lens comprises at least one
`substantially expanded zone
`and at least one substantially
`compressed zone.
`
`21. The panoramic objective
`lens according to claim 17,
`wherein the lens compresses
`the center of the image and
`the edges of the image, and
`expands an intermediate
`zone of the image located
`between the center and the
`edges of the image.
`
`
`
`
`
`
`
`Compressed
`edges
`
`LG V30 Series Smartphone
`
`
`Compressed center zone
`
`Compressed
`edges
`
`Expanded
`intermediate zone
`
`Expanded
`intermediate zone
`
`
`
`
`
`As indicated by its title, the above plot (produced as IV0004042) represents the derivatives of the linear point
`distribution function and the point distribution function of the LG V30 objective lens shown above. The Y axis
`represents the image resolution (in microns per degree) and the X axis represents the corresponding field angle of
`the lens. The LG V30 objective lens produces images with two substantially compressed zones: at the center of
`the image and around the edges of the image, where the blue dots fall below the red reference line, representing
`smaller resolution in these areas than a lens having a linear point distribution function. The LG V30 objective
`lens also produced a substantially expanded zone in between, from approximately 35 degrees to approximately 60
`degrees, where the blue dots rise above the red reference line, representing a higher resolution in this area than a
`lens having a linear point distribution function.
`
`4
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 11 of 23
`
`
`
`Claim
`
`17. A panoramic objective lens
`comprising:
`
`optical means for projecting
`a panorama into an image
`plane of the objective lens,
`the optical means having an
`image point distribution
`function that is not linear
`relative to the field angle of
`object points of the panorama,
`the distribution function having
`a maximum divergence of at
`least ±10% compared to a
`linear distribution function,
`such that a panoramic image
`obtained by means of the
`objective lens comprises at
`least one substantially
`expanded zone and at least one
`substantially compressed zone.
`
`21. The panoramic objective
`lens according to claim 17,
`wherein the lens compresses
`the center of the image and the
`edges of the image, and
`expands an intermediate zone
`of the image located between
`the center and the edges of the
`image.
`
`US PATENT 6,844,990, CLAIM 21 v. LG V35 SERIES SMARTPHONE
`
`LG V35 Series Smartphone
`
`As shown in the cross-sectional cut above (produced at IV0004045), the objective lens array within the LG G7
`contains a series of six lenses. The LG V35 contains the same wide-angle camera module (see public documents
`such as https://www.androidheadlines.com/2018/06/phone-comparisons-lg-v35-thinq-vs-lg-g7-thinq.html, as well
`as results of lens analysis below, which is nearly identical to lens analysis performed on LG G7 lens), and
`therefore the same lens array. When coupled together as in the G7 and V35, the lens array forms an objective lens
`that projects a panoramic image as described in the ‘990 Patent.
`
`1
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 12 of 23
`
`
`
`Claim
`
`17. A panoramic objective lens
`comprising:
`
`optical means for projecting a
`panorama into an image plane
`of the objective lens, the
`optical means having an
`image point distribution
`function that is not linear
`relative to the field angle of
`object points of the
`panorama, the distribution
`function having a maximum
`divergence of at least ±10%
`compared to a linear
`distribution function, such that
`a panoramic image obtained by
`means of the objective lens
`comprises at least one
`substantially expanded zone
`and at least one substantially
`compressed zone.
`
`21. The panoramic objective
`lens according to claim 17,
`wherein the lens compresses
`the center of the image and the
`edges of the image, and
`expands an intermediate zone
`of the image located between
`the center and the edges of the
`image.
`
`
`
`
`
`LG V35 Series Smartphone
`
`
`The above plot shows a normalized, linear point distribution function of an objective lens as a red line, wherein
`the Y axis represents the position of a point in an image with respect to the image center, and the X axis
`represents the field angle in degrees of the corresponding object point.
`
`The above plot also shows, in blue dots, measured position and field angle data (acquired using an Optikos
`LensCheck VIS and produced as IV0004038) for the wide-angle objective lens found in the LG V35. The lens
`array is panoramic as the lens reaches nearly 60 degrees away from center, resulting in a total field of view over
`110 degrees. The deviation of the function for the LG V35 objective lens away from the red line and multiple
`inflection points indicates that the image point distribution function of the LG V35 objective lens is not linear.
`
`2
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 13 of 23
`
`
`
`LG V35 Series Smartphone
`
`As shown in row 236 of the raw data taken from the measured point data of the LG V35 objective lens (produced
`at IV0004038), the image point distribution of the LG V35 objective lens has a maximum divergence from the
`linear distribution function of over 17%, exceeding the 10% divergence required by claim 17 of the ‘990 Patent.
`
`Claim
`
`17. A panoramic objective lens
`comprising:
`
`optical means for projecting a
`panorama into an image plane
`of the objective lens, the
`optical means having an image
`point distribution function that
`is not linear relative to the field
`angle of object points of the
`panorama, the distribution
`function having a maximum
`divergence of at least ±10%
`compared to a linear
`distribution function, such
`that a panoramic image
`obtained by means of the
`objective lens comprises at
`least one substantially
`expanded zone and at least one
`substantially compressed zone.
`
`21. The panoramic objective
`lens according to claim 17,
`wherein the lens compresses
`the center of the image and the
`edges of the image, and
`expands an intermediate zone
`of the image located between
`the center and the edges of the
`image.
`
`3
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 14 of 23
`
`
`
`Claim
`
`17. A panoramic objective lens
`comprising:
`
`optical means for projecting a
`panorama into an image plane
`of the objective lens, the
`optical means having an image
`point distribution function that
`is not linear relative to the field
`angle of object points of the
`panorama, the distribution
`function having a maximum
`divergence of at least ±10%
`compared to a linear
`distribution function, such that
`a panoramic image obtained
`by means of the objective
`lens comprises at least one
`substantially expanded zone
`and at least one substantially
`compressed zone.
`
`21. The panoramic objective
`lens according to claim 17,
`wherein the lens compresses
`the center of the image and
`the edges of the image, and
`expands an intermediate
`zone of the image located
`between the center and the
`edges of the image.
`
`Compressed
`edges
`
`LG V35 Series Smartphone
`
`Compressed center zone
`
`Compressed
`edges
`
`Expanded
`intermediate zone
`
`Expanded
`intermediate zone
`
`As indicated by its title, the above plot (produced as IV0004038) represents the derivatives of the linear point
`distribution function and the point distribution function of the LG V35 objective lens shown above. The Y axis
`represents the image resolution (in microns per degree) and the X axis represents the corresponding field angle of
`the lens. The LG V35 objective lens produces images with two substantially compressed zones: at the center of
`the image and around the edges of the image, where the blue dots fall below the red reference line, representing
`smaller resolution in these areas than a lens having a linear point distribution function. The LG V35 objective
`lens also produced a substantially expanded zone in between, from approximately 30 degrees to approximately 55
`degrees, where the blue dots rise above the red reference line, representing a higher resolution in this area than a
`lens having a linear point distribution function.
`
`4
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 15 of 23
`
`
`
`Claim
`
`17. A panoramic objective lens
`comprising:
`
`optical means for projecting
`a panorama into an image
`plane of the objective lens,
`the optical means having an
`image point distribution
`function that is not linear
`relative to the field angle of
`object points of the panorama,
`the distribution function having
`a maximum divergence of at
`least ±10% compared to a
`linear distribution function,
`such that a panoramic image
`obtained by means of the
`objective lens comprises at
`least one substantially
`expanded zone and at least one
`substantially compressed zone.
`
`21. The panoramic objective
`lens according to claim 17,
`wherein the lens compresses
`the center of the image and the
`edges of the image, and
`expands an intermediate zone
`of the image located between
`the center and the edges of the
`image.
`
`US PATENT 6,844,990, CLAIM 21 v. LG G8 SERIES SMARTPHONE
`
`LG G8 Series Smartphone
`
`As shown in the cross-sectional cut above (produced at IV0004040), the objective lens array within the LG G8
`contains a series of six lenses which, when coupled together as in the G8, form an objective lens that projects a
`panoramic image as described in the ‘990 Patent.
`
`1
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 16 of 23
`
`
`
`Claim
`
`17. A panoramic objective lens
`comprising:
`
`optical means for projecting a
`panorama into an image plane
`of the objective lens, the
`optical means having an
`image point distribution
`function that is not linear
`relative to the field angle of
`object points of the
`panorama, the distribution
`function having a maximum
`divergence of at least ±10%
`compared to a linear
`distribution function, such that
`a panoramic image obtained by
`means of the objective lens
`comprises at least one
`substantially expanded zone
`and at least one substantially
`compressed zone.
`
`21. The panoramic objective
`lens according to claim 17,
`wherein the lens compresses
`the center of the image and the
`edges of the image, and
`expands an intermediate zone
`of the image located between
`the center and the edges of the
`image.
`
`LG G8 Series Smartphone
`
`The above plot shows a normalized, linear point distribution function of an objective lens as a red line, wherein
`the Y axis represents the position of a point in an image with respect to the image center, and the X axis
`represents the field angle in degrees of the corresponding object point.
`
`The above plot also shows, in blue dots, measured position and field angle data (acquired using an Optikos
`LensCheck VIS and produced as IV0004041) for the wide-angle objective lens found in the LG G8. Te lens array
`is panoramic as the lens reaches over 55 degrees away from center, resulting in a total field of view over 110
`degrees. The deviation of the function for the LG G8 objective lens away from the red line and multiple
`inflection points indicates that the image point distribution function of the LG G8 objective lens is not linear.
`
`2
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 17 of 23
`
`
`
`LG G8 Series Smartphone
`
`As shown in row 39 of the raw data taken from the measured point data of the LG G8 objective lens (produced at
`IV0004041), the image point distribution of the LG G8 objective lens has a maximum divergence from the linear
`distribution function of over 19%, exceeding the 10% divergence required by claim 17 of the ‘990 Patent.
`
`Claim
`
`17. A panoramic objective lens
`comprising:
`
`optical means for projecting a
`panorama into an image plane
`of the objective lens, the
`optical means having an image
`point distribution function that
`is not linear relative to the field
`angle of object points of the
`panorama, the distribution
`function having a maximum
`divergence of at least ±10%
`compared to a linear
`distribution function, such
`that a panoramic image
`obtained by means of the
`objective lens comprises at
`least one substantially
`expanded zone and at least one
`substantially compressed zone.
`
`21. The panoramic objective
`lens according to claim 17,
`wherein the lens compresses
`the center of the image and the
`edges of the image, and
`expands an intermediate zone
`of the image located between
`the center and the edges of the
`image.
`
`3
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 18 of 23
`
`
`
`Claim
`
`17. A panoramic objective lens
`comprising:
`
`optical means for projecting a
`panorama into an image plane
`of the objective lens, the
`optical means having an image
`point distribution function that
`is not linear relative to the field
`angle of object points of the
`panorama, the distribution
`function having a maximum
`divergence of at least ±10%
`compared to a linear
`distribution function, such that
`a panoramic image obtained
`by means of the objective
`lens comprises at least one
`substantially expanded zone
`and at least one substantially
`compressed zone.
`
`21. The panoramic objective
`lens according to claim 17,
`wherein the lens compresses
`the center of the image and
`the edges of the image, and
`expands an intermediate
`zone of the image located
`between the center and the
`edges of the image.
`
`Compressed
`edges
`
`LG G8 Series Smartphone
`
`Compressed center zone
`
`Compressed
`edges
`
`Expanded
`intermediate zone
`
`Expanded
`intermediate zone
`
`As indicated by its title, the above plot (produced as IV0004041) represents the derivatives of the linear point
`distribution function and the point distribution function of the LG G8 objective lens shown above. The Y axis
`represents the image resolution (in microns per degree) and the X axis represents the corresponding field angle of
`the lens. The LG G8 objective lens produces images with two substantially compressed zones: at the center of the
`image and around the edges of the image, where the blue dots fall below the red reference line, representing
`smaller resolution in these areas than a lens having a linear point distribution function. The LG G8 objective lens
`also produced a substantially expanded zone in between, from approximately 30 degrees to approximately 55
`degrees, where the blue dots rise above the red reference line, representing a higher resolution in this area than a
`lens having a linear point distribution function.
`
`4
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 19 of 23
`
`
`
`Claim
`
`17. A panoramic objective lens
`comprising:
`
`optical means for projecting
`a panorama into an image
`plane of the objective lens,
`the optical means having an
`image point distribution
`function that is not linear
`relative to the field angle of
`object points of the panorama,
`the distribution function having
`a maximum divergence of at
`least ±10% compared to a
`linear distribution function,
`such that a panoramic image
`obtained by means of the
`objective lens comprises at
`least one substantially
`expanded zone and at least one
`substantially compressed zone.
`
`21. The panoramic objective
`lens according to claim 17,
`wherein the lens compresses
`the center of the image and the
`edges of the image, and
`expands an intermediate zone
`of the image located between
`the center and the edges of the
`image.
`
`
`
`
`
`US PATENT 6,844,990, CLAIM 21 v. LG V50 SERIES SMARTPHONE
`
`LG V50 Series Smartphone
`
`
`As shown in the cross-sectional cut above (produced at IV0005512), the objective lens array within the LG V50
`contains a series of six lenses which, when coupled together as in the LG V50, form an objective that projects a
`panoramic image as described in the ‘990 Patent.
`
`1
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 20 of 23
`
`
`
`Claim
`
`17. A panoramic objective lens
`comprising:
`
`optical means for projecting a
`panorama into an image plane
`of the objective lens, the
`optical means having an
`image point distribution
`function that is not linear
`relative to the field angle of
`object points of the
`panorama, the distribution
`function having a maximum
`divergence of at least ±10%
`compared to a linear
`distribution function, such that
`a panoramic image obtained by
`means of the objective lens
`comprises at least one
`substantially expanded zone
`and at least one substantially
`compressed zone.
`
`21. The panoramic objective
`lens according to claim 17,
`wherein the lens compresses
`the center of the image and the
`edges of the image, and
`expands an intermediate zone
`of the image located between
`the center and the edges of the
`image.
`
`LG V50 Series Smartphone
`
`The above plot shows a normalized, linear point distribution function of an objective lens as a red line, wherein
`the Y axis represents the position of a point in an image with respect to the image center, and the X axis
`represents the field angle in degrees of the corresponding object point.
`
`The above plot also shows, in blue dots, measured position and field angle data (acquired using an Optikos
`LensCheck VIS and produced as IV0004961) for the wide-angle objective lens found in the LG V50. The lens
`array is panoramic as the lens reaches over 55 degrees away from center, resulting in a total field of view over 110
`degrees. The deviation of the function for the LG V50 objective lens away from the red line and multiple
`inflection points indicates that the image point distribution function of the LG V50 objective lens is not linear.
`
`2
`
`LGE Exhibit 1011
`LGE v. ImmerVision
`Page 21 of 23
`
`
`
`LG V50 Series Smartphone
`
`As shown in row 115 of the raw data tak
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